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Poland’s draft EUDR implementing law: new obligations, more controls and material business risk

On 9 April 2026, Poland published draft bill UC101 intended to implement the EUDR framework at national level. For businesses trading in timber, coffee, cocoa, soy, rubber, palm oil, cattle and related products, this may mean not only new documentation requirements, but also increased enforcement exposure and potentially severe penalties.

Draft bill UC101 is designed to ensure the application in Poland of Regulation (EU) 2023/1115 (EUDR), which aims to reduce the EU market’s contribution to deforestation and forest degradation. The EUDR covers cattle, cocoa, coffee, oil palm, rubber, soy and wood, as well as certain derived products, and requires Member States to designate competent authorities and establish control and enforcement mechanisms. According to Poland’s legislative work programme, UC101 falls within the remit of the Ministry of Climate and Environment, with adoption by the Council of Ministers planned for Q3 2026.

Based on the currently available assumptions, the Polish legislation is expected to regulate, among other things, the submission of due diligence statements, the exchange of information with authorities, inspection procedures, corrective measures and cooperation with customs authorities. The legislative summary also identifies the competent authorities for particular commodity groups, including the Environmental Protection Inspection, IJHARS and the Veterinary Inspection.

From an operational perspective, one of the most relevant elements is the proposed requirement to include the reference number of the due diligence statement. Public commentary on the draft indicates that this number, or the identifier of a simplified declaration, would need to appear in commercial offers and transaction documents, including online sales. The absence of a valid number may also lead customs authorities to refuse acceptance of a customs declaration for release for free circulation or export.

The sanctions framework also deserves close attention. Commentary on the draft points to administrative fines of up to 10% of annual turnover and, in the most serious or repeated cases, a temporary ban on carrying out activities involving the relevant products. This means that EUDR is becoming not only a compliance challenge, but also a genuine operational and business risk.

For businesses, the key question is whether their supply chain, trade documentation and customs processes are ready for the new regime. In practice, companies should already assess whether they have the data, procedures and internal allocation of responsibilities necessary to demonstrate compliance once the Polish rules enter into force.

If you would like to discuss draft bill UC101 and its potential impact on your business, please contact us.

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